US Sectoral Sanctions

What's Newest (cont'd) Recent measures under Venezuela and Iran sanctions programs - possible effects on/for Russia - Venezuela Iran Rosneft's sale of all its Venezuela assets - after its two Swiss subs, Rosneft Trading S.A. and TNK Trading International S.A., were SDN-designated in Feb.-March 2020 (along with RT's Chairman and President) for buying/trading Venezuela crude; and then announcement that Rosneft is closing down these subs because of the SDN-related disruption caused (and new Swiss trading co., Energopole S.A., has been established by Rosneft) further 2020 designation of several shipping companies and individual vessels, for having carried Venezuelan crude - no Russian ones yet, but also could have some Russia reverberations - see this Nov. 2020 investigative press report and most recent 30 Nov. designation of CEIEC, a leading Chinese telecoms-tech company, for alleged cyber assistance to Venezuelan state telecoms company in stifling political dissent - see OFAC press release two subs of a Chinese state shipping giant, SDN-designated in Sept. 2019 for carrying Iranian crude - then one delisted in Jan. 2020, resolving a fallout effect on carriage of Novatek's Yamal LNG project cargos (see slide 44) further new Iran sanctions aimed at the refining and petrochemicals, mining & metals, manufacturing, construction, and textiles sectors (e.g., EO 13902 of Jan. 2020 and various related designations since then (including 17 Sept. 2020)) - could have effects for Russia / require heightened caution by Russian companies and see OFAC 8 Oct. announcement of SDN designations of several Iranian banks, and related general licenses and FAQs And various new Russian co. designations under North Korea sanctions regimes as well (19 Nov. and 24 Nov. 2020) - and see 8 Dec. designations of (non-Russia) entities and vessels for carrying North Korea coal Also note these other provisions in the NDAA 2020 and 2021 (see slides 7 above and 62 below) Venezuela sanctions (NDAA 2020, section 890 et seq.), including US Defense Dep't procurement restrictions for any company (and its corporate group) that does unlicensed business with any Venezuelan Gov't authority/agency/entity Syria sanctions (NDAA 2020, section 7401 et seq.), requiring imposition of sanctions on non-US persons that knowingly engage with the Gov't of Syria (and its owned/controlled entities) in certain ways, including ... facilitating the maintenance or expansion of Syria's domestic production of natural gas, petroleum, or petroleum products North Korea sanctions (NDAA 2020, section 7101 et seq.) which could also have enhanced consequences for Russian companies and financial institutions Turkey sanctions mandate (impending NDAA 2021, section 1241), for purchase of Russian S-400 missile system (see slide 42) And see OFAC's 14 May 2020 Guidance to Address Illicit Shipping and Sanctions Evasion Practices Morgan Lewis 11

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